Privacy policy
Last updated: [INSERT DATE]
This Privacy Policy explains how B&E Academy Ltd, trading as Upgrade Economics ("we", "us" or "our"), collects, uses, stores and protects personal information when you visit our website, book private tutoring, join our online tutoring membership, access our pre-recorded educational content, attend our live Monday Q&A sessions, or contact us.
We take privacy seriously and are committed to handling personal information fairly, lawfully and transparently.
This Privacy Policy applies to both adult and under-18 members.
1. Who we are
Business name: B&E Academy Ltd, trading as Upgrade Economics (company number 12649599)
Business address: 4 Lock Court, Brize Norton, Carterton, OX18 1NS
Email: liam@upgradeeconomics.co.uk
Website: https://www.upgradeeconomics.co.uk
For the purposes of applicable UK data protection legislation, including the UK GDPR and Data Protection Act 2018, B&E Academy Ltd is the data controller for the personal information we process in connection with our business, except where another organisation acts as a separate data controller for its own processing.
If you have any questions about this Privacy Policy or how we use personal information, please contact us using the details above.
2. Information we collect
We aim to collect only the personal information that we reasonably need to provide and administer our service.
Depending on how you use our service, we may collect:
- name;
- email address;
- telephone number, where provided;
- date of birth or age, where necessary to establish age or provide appropriate protections;
- parent or guardian contact details, where applicable;
- membership and account information;
- billing and subscription information;
- payment and transaction information;
- information you provide when contacting us;
- questions, comments or messages submitted during a live Q&A;
- feedback, reviews or testimonials that you voluntarily provide; and
- technical information relating to your use of our website and membership platform.
We may also automatically collect certain technical information when you use our website or membership platform, such as:
- IP address;
- browser and device information;
- operating system;
- pages or content accessed;
- dates and times of access; and
- information about how you use our website and membership platform.
We will not ask you to provide personal information that is unnecessary for the service.
3. Children's information
Our membership may be used by people under the age of 18.
We recognise that children require additional protection in relation to their personal information. We therefore take children's privacy into account when designing and operating our service.
We aim to:
- collect only the information necessary to provide the membership;
- use privacy-protective settings wherever reasonably possible;
- limit the information visible to other members;
- avoid unnecessary sharing of children's personal information;
- provide privacy information in clear and understandable language;
- avoid encouraging children to provide unnecessary personal information; and
- take the best interests of children into account when deciding how their information is processed.
The ICO's Children's Code applies to online services likely to be accessed by children and recommends, among other things, high privacy settings by default, data minimisation and careful control of children's data sharing.
Where appropriate, we may ask for a member's age or date of birth so that we can apply appropriate safeguards.
We will only collect and retain information used for age assurance where reasonably necessary and will not use it for unrelated purposes.
4. Parents and guardians
Where a member is under 18, a parent or guardian may purchase or manage the membership on the child's behalf.
Where appropriate, we may communicate with a parent or guardian about the child's membership, particularly where this is necessary for the administration, safety or safeguarding of the service.
A parent or guardian may contact us regarding a child's personal information, although we may need to verify their identity and their relationship with the child before providing information.
Children may also have their own data protection rights. We will consider requests from children in accordance with applicable data protection law and their age and understanding.
5. Private tutoring
We also provide private tutoring, face to face and online. If you or your child book tutoring, we may collect the student's name and age or year group, a parent or guardian's name and contact details, the subject and exam board, details of topics covered and progress, scheduling information and payment records.
We use this information to arrange and deliver sessions, to tailor teaching, to communicate about sessions, to take payment and to keep records we are legally required to keep. Our lawful basis is usually contract, and legal obligation for accounting records.
Where sessions take place online we use Microsoft Teams, whose own privacy information applies.
We keep tutoring records for as long as the tutoring continues and for a reasonable period afterwards, and accounting records for as long as the law requires.
6. Enquiries and messages
If you contact us by email, by a messaging service such as WhatsApp, or using the contact details on our website, we will use the information you give us to reply and to take any steps you ask for before a booking or purchase.
Your messages may also be processed by the service you use to send them, such as your email provider or WhatsApp, which have their own privacy policies.
We rely on our legitimate interest in responding to enquiries, or on taking steps at your request before entering a contract. If you do not become a customer, we will not keep your enquiry for longer than reasonably necessary.
7. How we use personal information
We may use personal information to:
- create and manage membership accounts;
- provide access to pre-recorded educational content;
- provide access to live Monday Q&A sessions;
- communicate with members about their membership;
- provide customer support;
- process payments and subscriptions;
- administer cancellations and refunds;
- answer questions submitted during live Q&A sessions;
- maintain the security of our website and membership platform;
- monitor and improve our service;
- prevent fraud, misuse or unauthorised access;
- comply with legal and regulatory obligations; and
- establish, exercise or defend legal claims.
We will not use children's personal information for unnecessary profiling or behavioural advertising.
We will not sell personal information.
8. Lawful bases for processing
We must have a lawful basis under UK data protection law for processing personal information. Depending on the circumstances, we may rely on:
Contract. We may process information where necessary to provide the membership that you have purchased. For example, we need your name and email address to create your account and provide access to the membership.
Legal obligation. We may process information where necessary to comply with a legal or regulatory obligation, including applicable accounting, tax and legal requirements.
Legitimate interests. We may process information where this is reasonably necessary for our legitimate interests, provided that those interests are not overridden by your rights and interests. This may include:
- administering our business;
- maintaining platform security;
- preventing fraud and misuse;
- improving our services;
- communicating with members about service-related matters; and
- establishing, exercising or defending legal claims.
Where we rely on legitimate interests, we will consider whether the processing is necessary and proportionate.
Consent. Where consent is required by law, we will ask for consent before processing personal information for the relevant purpose. Where we rely on consent, it can be withdrawn at any time. Withdrawing consent does not affect processing that took place before consent was withdrawn.
9. Live Monday Q&A sessions
Our membership currently includes a live Q&A session every Monday at 5:00pm UK time.
The sessions are hosted using Microsoft Teams. The Q&A sessions are not recorded by us.
If you participate in a live Q&A, other participants may be able to see information that you choose to make available during the session, such as your name, display name, profile information, questions, comments or other information you voluntarily share.
For your own privacy, you should avoid sharing unnecessary personal information during a live session.
If you are under 18, we particularly recommend that you do not share your home address, telephone number, school address, passwords or other unnecessary personal information during a live session.
We will not intentionally ask children to disclose unnecessary personal information during Q&A sessions.
Microsoft Teams may itself process personal and technical information in connection with providing the service. Microsoft's own privacy terms and information apply to Microsoft's processing.
10. Information visible to other members
Our service may involve interactions between members, including during live Q&A sessions.
We will take reasonable steps to minimise unnecessary disclosure of members' personal information.
Where our platform provides privacy or visibility settings, we will use privacy-protective settings where reasonably possible.
We will not intentionally make children's personal information publicly visible unless there is a clear and lawful reason for doing so.
Members should also respect the privacy of other members and must not copy, record, screenshot, publish or distribute another person's personal information without appropriate permission and a lawful basis.
11. Payment information
Our membership costs £25 per month.
Payments and recurring subscriptions are processed using our third-party payment provider. We do not generally store complete payment card details ourselves. Our payment provider may collect and process payment information in accordance with its own privacy policy.
We may retain information such as:
- payment date;
- payment amount;
- payment status;
- subscription status; and
- limited transaction information.
We retain this information where necessary for accounting, customer service, fraud prevention and legal purposes.
Payment provider: Stripe (privacy information: https://stripe.com/gb/privacy)
12. Membership.io
Our online membership is provided through Membership.io.
Membership.io may process personal information necessary to create and manage your membership account and provide access to our educational content.
Membership.io privacy information: [INSERT LINK]
We will only provide Membership.io with information reasonably necessary for the operation of the membership, subject to the applicable contractual and data protection arrangements.
13. Microsoft Teams
Our live Monday Q&A sessions are hosted using Microsoft Teams.
When you join a Teams session, Microsoft may process information such as your account details, device information, meeting participation information and other technical information required to provide the Teams service. Microsoft's own privacy information explains how it processes personal data in Teams.
Microsoft Privacy Statement: https://privacy.microsoft.com/en-gb/privacystatement
We do not record our Monday Q&A sessions.
14. Marketing
We may send marketing communications where permitted by applicable law.
You can unsubscribe from marketing communications at any time. Unsubscribing will not prevent us from sending essential service messages, such as information about your membership, payments, security or important changes to our service.
We will not use children's personal information for targeted advertising or unnecessary marketing.
15. Our website, embedded videos and cookies
Hosting. Our website is hosted by Cloudflare. When you visit, Cloudflare processes technical information such as your IP address and browser details to deliver the pages and protect the site from attacks. Cloudflare privacy policy: https://www.cloudflare.com/privacypolicy/
Fonts. Our website uses fonts loaded from Google Fonts, so your browser connects to Google's servers, which receive your IP address and technical information.
Embedded videos. Our free lessons are YouTube videos embedded using YouTube's privacy-enhanced mode. When a page with an embedded video loads, your browser connects to YouTube (Google), which receives your IP address and technical information. If you play a video, Google may also collect information about your viewing and may set cookies. Google privacy policy: https://policies.google.com/privacy
Links to other sites. Our website links to our Facebook and TikTok pages. If you follow those links, the privacy policies of those services apply.
Cookies. Our own website pages do not set cookies for analytics or advertising. Our membership platform uses cookies that are necessary for login and security, and the third-party services described above may set cookies of their own. If we add analytics or other non-essential cookies, we will ask for your consent where the law requires it and update this policy.
16. Who we share information with
We may share personal information with trusted third parties where necessary to operate our business, including:
- Membership.io;
- payment providers;
- Microsoft Teams/Microsoft;
- website and hosting providers (currently Cloudflare);
- Google (embedded YouTube videos and website fonts);
- email and communication providers (including WhatsApp);
- IT and security providers;
- professional advisers such as accountants and lawyers;
- insurers, where necessary; and
- government bodies, regulators or law enforcement where legally required or permitted.
We do not sell personal information.
We will only share personal information where we have an appropriate lawful basis and will seek to minimise the information shared. Where children's information is involved, we will take particular care to minimise unnecessary sharing.
17. International transfers
Some of the organisations we use may process personal information outside the UK.
Where personal information is transferred outside the UK, we will take appropriate steps to ensure that the transfer is lawful under applicable UK data protection law. This may include relying on an adequacy decision, appropriate safeguards or another legally permitted transfer mechanism.
18. How long we keep information
We will not keep personal information for longer than reasonably necessary. The retention period will depend on the type of information and why we collected it. For example:
- account information will generally be retained while your membership is active and for a reasonable period afterwards;
- transaction and accounting records may be retained for the period required by tax and accounting law;
- customer service correspondence may be retained for as long as reasonably necessary;
- information relating to complaints or disputes may be retained for as long as necessary to resolve and document the matter; and
- marketing information will generally be retained until you unsubscribe or it is no longer required.
Where a child leaves the service, we will review the personal information we hold and delete information that is no longer reasonably required, subject to any legal or legitimate retention requirement.
19. Security
We take reasonable technical and organisational measures to protect personal information against:
- unauthorised access;
- accidental loss;
- destruction;
- misuse;
- alteration; and
- unauthorised disclosure.
We limit access to personal information to people and organisations that reasonably need it.
However, no internet-based service can be guaranteed to be completely secure. Members should keep their account login details confidential and notify us promptly if they believe their account has been compromised.
20. Your data protection rights
Depending on the circumstances, you may have rights under UK data protection law including:
- the right to know how we use your personal information;
- the right to request access to your personal information;
- the right to request correction of inaccurate information;
- the right to request deletion of personal information in certain circumstances;
- the right to request restriction of processing in certain circumstances;
- the right to object to certain processing;
- the right to data portability in certain circumstances; and
- the right to withdraw consent where we rely on consent.
These rights are subject to legal conditions and exemptions.
Children can also have data protection rights. We will consider requests made by children in an appropriate manner, taking account of their age, understanding and the nature of the request.
21. Exercising your rights
To exercise a data protection right or ask a question about your personal information, contact:
B&E Academy Ltd, trading as Upgrade Economics
Email: liam@upgradeeconomics.co.uk
Address: 4 Lock Court, Brize Norton, Carterton, OX18 1NS
We may need to verify your identity before responding to a request. We will normally respond within the timeframe required by applicable data protection law.
22. Complaints
If you have concerns about how we handle your personal information, please contact us first so that we can try to resolve the issue.
You also have the right to complain to the Information Commissioner's Office (ICO), the UK's independent data protection regulator.
ICO website: https://ico.org.uk
23. Changes to this Privacy Policy
We may update this Privacy Policy from time to time to reflect changes to our business, technology, services or legal requirements.
Where appropriate, we will notify members of significant changes.
The latest version will always be available on our website.
Last updated: [INSERT DATE]